UNITED STATES DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
Klamath Falls Resource Area
DECISION RECORD #2
FOR
OREGON GULCH FIRE SALVAGE AND REHABILITATION
ENVIRONMENTAL ASSESSMENT
#DOI-BLM-OR-L040-2015-01-EA
INTRODUCTION
The potential effects of multiple proposed actions are analyzed in the Oregon Gulch
Environmental Assessment (EA) #DOI-BLM-OR-L040-2015-01. This Decision Record #2
applies only to the forest management actions analyzed in the EA such as timber salvage, tree
planting, and associated road management actions. The previous Decision Record #1 applied to
fire rehabilitation treatments such as fence repair and construction, noxious weed (medusahead
rye) treatment, seeding, and replacement of a wildlife guzzler. Voluntary agreements have
already been signed with the two range permittees to temporarily suspend livestock grazing in
the burned portions of the Dixie and Edge Creek Allotments, so resting the allotments was not
included in either Decision.
The Klamath Falls Resource Area (KFRA) interdisciplinary team analyzed the proposed actions
based on: (a) current resource conditions in the project area, (b) the results of monitoring
previous activities within and surrounding the project area, (c) meeting the purpose and need as
identified in the Oregon Gulch EA, (d) implementation of the management action and direction
stipulated in the 1995 Klamath Falls Resource Area Resource Management Plan (RMP), and (e)
comments from the public. The proposals presented and evaluated in the Oregon Gulch EA
reflect what the interdisciplinary team determined to be the best balance and integration of
resource conditions, resource potentials, competing management objectives, and expressed
interests and concerns of the public.
DECISION
It is my decision to implement a combination of Alternatives 3 and 4 for the proposed forest
management actions, along with all of the project design features (PDFs) and best management
practices (BMPs) listed on pages 13-15 of the EA.
Alternative 3 will be applied on Matrix lands only. Alternative 4 will be implemented on District
Designated Reserves (DDRs - also referred to as Late Successional Reserves (LSRs) throughout
the EA), Riparian Reserves (RR), and Areas of Critical Environmental Concern (ACEC). These
treatments are summarized in Table 1 below, followed by a detailed description, and my decision
rationale. The treatments are also displayed on the attached Decision Record #2 Map.
Decision Record #2 – Oregon Gulch Environmental Assessment
Page 1 of 8
Table 1. Treatments Selected (in bold) by Action Alternative
Area or
Treatment
Alternative 2
Alternative 3
Salvage harvest approx.
1,650 acres in Matrix
Salvage and
Snag Retention
in Matrix
Retain 10 snags per acre. As a
minimum, retain the 4 largest
snags available per acre and
retain 6 snags in the 10-20
inch diameter range per
acre.
Retain all standing snags
10”dbh and less.
As a minimum, retain 2.6
conifer snags per acre
(decay class one and two)
with a minimum diameter of
20 inches on one snag and
greater than 16 inches on
the 1.6 snags (see PDFs in
EA for details).
Retain standing snags
10”dbh and less.
Salvage in
District
Designated
Reserves (DDRs)
Salvage in
Riparian
Reserves(RR)
Salvage in
Area of Critical
Environmental
Concern (ACEC)
Salvage in
NSO Dispersal
habitat (no NRF)
Road
Construction
Tree Planting
(All action alternatives)
Road Closures
(0.81 mile total)
Partial harvest
Retain all snags 16” DBH
and larger
Yes, same snag retention as
Matrix
No – inner
Yes –outer, but retain all
snags 16” DBH and larger
Yes – inner and outer,
same snag retention as
Matrix
Partial harvest
Retain all snags 16” DBH
and larger
Yes, same snag retention as
Matrix
Alternative 4
Reserve from post-fire salvage
logging 40% of the KFRA
forested acreage within the
fire perimeter that has the
highest potential for blackbacked woodpecker
occupancy.
On the remaining 1,578 acres,
conduct salvage operations,
but as a minimum, retain 3
snags per acre (one 20+" snag
and two 16+" snags per
acre). Remove all standing
snags 10” dbh and less on the
1,578 acres.
No salvage in DDRs
No salvage in RR
No salvage in ACEC
No harvest of trees with
live canopy
Yes - harvest of dead
and dying trees
No
Yes, 0.30 mile
No
Yes
Yes
Yes
Yes
Yes
Yes
No harvest of trees with
live canopy
Alternative 3 for Matrix lands
The EA displayed the project area as 4,870 acres, including approximately 3,424 acres of Matrix
lands. The actual project area is 4,865 acres after ground-truthing the fire perimeter.
Approximately 1,650 acres of Matrix lands will be salvage harvested and planted. The EA
displayed 1,796 acres available for salvage under Alternative 3, but units were adjusted during
on-the-ground layout due to concerns such as access, operational feasibility, and cultural
resources.
Snag retention: In all salvage harvest units, 2.6 snags per acre (decay class one and two) will be
retained, with a minimum diameter of 20 inches diameter at breast height (DBH) for one snag,
Decision Record #2 – Oregon Gulch Environmental Assessment
Page 2 of 8
and greater than 16 inches DBH for the other 1.6 snags (see PDFs for details). Standing dead or
dying trees 10” DBH and greater will be available for harvest. Standing dead or dying snags 10”
DBH and less will be retained. The BLM will use guidelines from the Southwest Oregon Forest
Insect and Disease Service Center (SWOFIDSC) to assist in identifying trees with some live
canopy, but with a high probability of fire-caused mortality. The “Predicted Tree Mortality by
Species” guidelines (SWOFIDSC, 2001) displayed on page 10 of the EA will be used to assess
fire-injured trees.
Northern Spotted Owl (NSO) Dispersal Habitat: Dead and fire-injured trees within 135 acres
of NSO dispersal habitat will be salvaged using the same “Predicted Tree Mortality by Species”
guidelines as described above for Matrix lands.
Whole tree yarding: Trees will be removed and harvested by whole-tree yarding and groundbased logging systems. Cable yarding will be used to harvest stands on slopes averaging greater
than 35% in Unit 31-2. In areas of the unit with favorable slopes less than 35%, a ground-based
mechanical harvesting system will be used to cut and yard timber.
Slash treatment: Slash will be utilized or piled and burned at landings to reduce future
hazardous fuels conditions. Utilization methods could include spreading some slash on skid
trails, chipping, grinding, or firewood.
Conifer planting in salvage harvest units: Following salvage harvest, the same 1,650 acres of
Matrix lands will be planted by hand with a mix of ponderosa pine, sugar pine, Douglas-fir and
incense cedar seedlings. An additional 249 acres of Matrix lands that were not proposed for
salvage harvest (due to lack of access, density, or economic feasibility) will also be planted.
Roadside and hazard tree removal: Throughout treatment stands, near landings, and along all
system roads, hazard trees as identified in the Field Guide for Danger Tree Identification and
Response (USDA and DOI 2008) will be felled to ensure contractor and public safety. Roadside
hazard trees felled within stands being salvage harvested will be removed from the site during
salvage operations. On Reciprocal Right of Way (ROW) roads (M/L-690), hazard trees as
defined above will be felled and removed by the holder of the ROW permit or left in place at
their discretion.
Road construction: A road approximately 0.30 mile in length will be constructed in Unit 31-2
(see Map 1 in Appendix A of the EA) to provide access for cable logging approximately 32 acres
of Matrix lands. The road will be decommissioned (closed) following project activities. This
road will be needed for future resource management so it will not be fully decommissioned
(permanently closed), but it will be blocked to prevent vehicle use. Closure methods could
include scarifying the surface, installing water bars, scattering slash and other debris along the
length, and camouflaging and blocking the entrance using an earthen berm, logs, boulders or a
combination of these methods.
Road decommissioning: Three unsurfaced “shortcut” connector roads which total
approximately 0.81 mile in length will be fully decommissioned (permanently closed), as
described on page 9 of the EA under “Treatments Common to All Action Alternatives,” and
displayed on Map 3 in Appendix A of the EA. These spur roads are not needed for management
purposes in the foreseeable future.
Decision Record #2 – Oregon Gulch Environmental Assessment
Page 3 of 8
Alternative 4 for DDRs, RRs, and ACEC
I have chosen to apply Alternative 4 to the 1,446 acres of DDR, RR, and ACEC in the project
area as follows:
• District Designated Reserve (DDR): No salvage harvest in DDR (also called LSR in the
EA). Conifers will be planted on approximately 192 acres of DDR.
• Riparian Reserve (RR): No salvage harvest in RRs. Conifers will be planted on
approximately 198 acres of RRs.
• Areas of Critical Environmental Concern (ACEC): No salvage harvest in ACEC.
Conifers will be planted on approximately 302 acres of ACEC.
DECISION RATIONALE
I am confident that the Oregon Gulch EA plus the supplemental information, including public
comments on the EA and BLM responses to those comments, in addition to the comprehensive
analysis done in the Klamath Falls Resource Area RMP/EIS to which the EA is tiered, represents
a thorough analysis of potential effects associated with actions identified in the EA.
I have chosen this combination of Alternatives 3 and 4 for the proposed forest management
actions because these treatments best meet the Purpose and Need, and the direction established in
the Klamath Falls Resource Area RMP for the following reasons:
Salvage harvest only on Matrix lands
I have chosen to maximize salvage harvest on Matrix lands (as proposed in Alternative 3) and
not to salvage harvest in DDRs (also called LSRs), RRs, and ACECs (as proposed in Alternative
4). I feel that this combination best meets the project’s Purpose and Need for timely salvage
harvest in order to capture merchantable timber values before further wood deterioration occurs
(EA, pg. 3) while balancing the need for a healthy forest ecosystem that will support populations
of native species and includes protection for riparian areas and waters (EA, pg. 4).
My Decision will authorize approximately 1,650 acres of salvage harvest, which represents
approximately 34% of the 4,865-acre project area. The remaining 3,215 acres (66%) of the
project area that will not be salvaged consists of both forested and non-forested acres, as shown
below in Table 2.
Table 2. Acres salvaged vs. reserved from salvage by cover type
Habitat type
Acres
(approximate*)
Percent of Project
Area (4,865 acres)
Salvage Harvest Units
1,650
34%
Acres reserved from salvage harvest
3,215
66%
Forest (unsalvaged)
880
Non-forest (meadows,scab rock,etc)
785
Woodlands**
1,550
*Acres rounded to the nearest 5.
** “Woodlands” in BLM Forest Inventory data consist of a variety of cover conditions ranging from dense conifer
stands including pine, Douglas-fir, cedar and juniper to open oak and brush savannahs. They are not classified
as forest land due to the uneven nature of the stocking and potential reforestation issues.
Decision Record #2 – Oregon Gulch Environmental Assessment
Page 4 of 8
Retain 2.6 Snags per acre
It is my decision to retain 2.6 snags per acre over the 1,650 acres of salvage units. Reserving 2.6
snags per acre corresponds to the minimum number of snags required in the RMP and 2001
Record of Decision (ROD). Prior to the Oregon Gulch Fire, the project area was deficit of coarse
wood based on the management direction in the KFRA RMP (pg. 23) where it states “leave 120
linear feet of logs greater than 16 inches in diameter and 16 feet long on Matrix lands.” The
management direction (pg. 23) also states to retain snags within timber harvest units at levels
sufficient to support species at 60% of potential levels, which equates to 1.9 snags per acre (RMP
pg. 33). In the salvage harvest units, an additional 0.7 snags per acre will be retained to meet the
standard and guidelines in the 2001 ROD for the white-headed and black-backed woodpeckers,
pygmy nuthatch and flammulated owl (RMP pg. 33-34). The coarse wood deficit described
above is not expected to persist in the project area as snags begin to fall due to decay and
weather events in the near future. In addition, on all unsalvaged areas (approximately 3,215
acres or 66% of analysis area) all of the snags, except hazard trees, will be reserved.
I did not choose to retain 10 snags per acre on Matrix lands (as suggested by some EA
commenters) because the analysis showed no difference in impacts to cavity-nesting species such
as the black-backed woodpecker (BBWP) when retaining 10 snags per acre (as proposed in
Alternative 2) vs. 2.6 snags per acre (as proposed in Alternative 3). As stated in the EA on pages
51-52, “[t]he BBWP appears to be to most demanding in terms of snag density, of the
woodpecker species likely to inhabit the Oregon Gulch fire, and exhibits a strong preference for
stands not altered by timber salvage activity… Stands that are subject to even minimal salvage
logging have a substantially reduced suitability for BBWP reproduction. This is not to say that
BBWP will never be found occupying or reproducing in stands subject to timber salvage, but
rather that given the state of knowledge on BBWP habitat relationships and their strong
preference for high snag density patches, BLM cannot reliably count on stands subjected to
timber salvage to provide for the needs of successfully reproducing BBWPs, or to provide for the
population boom that this species is known for in post-fire forest habitat.” The EA analysis also
indicated that some other cavity nesting species, such as the Lewis’ Woodpecker, may benefit
from more open spaces (EA pgs. 51-58). In addition, all snags will be retained on the majority
of the project area (approximately 3,215 acres or 66% of analysis area).
Another reason I did not choose to retain 10 snags per acre on Matrix lands was due to
economics. The EA economic analysis indicated that reserving 10 snags per acre would reduce
the available Matrix harvest volume by approximately 6.6 million board feet (MMBF) compared
to retaining 2.6 snags per acre. The estimated value of that 6.6 MMBF is approximately
$990,000. These volume and cost figures are based on the original acreage estimates found in the
Economic Section of the EA, pages 32-39.
Retention of snags 10” DBH and smaller
Within salvage harvest units, I have decided to retain all snags 10 inches diameter at breast
height (DBH) and smaller primarily due to adverse economic impacts associated with their
removal, and the lack of a substantial difference in fuel loads and predicted fire behavior, as
analyzed in the EA (pg. 68-70). In addition, the retention of these snags will benefit many
wildlife species and contribute to woody debris for nutrient cycling and wildlife (EA, pg. 46-65).
Decision Record #2 – Oregon Gulch Environmental Assessment
Page 5 of 8
Northern Spotted Owl (NSO) Dispersal Habitat
My decision includes salvage of dead and dying trees in 135 acres of NSO dispersal habitat,
using the “Predicted Tree Mortality by Species” guidelines, as proposed in Alternative 3. I have
based my decision on the analysis found on page 45 in the EA: “Because the dispersal habitat
removal caused by removing dying green trees from the 135 acres of post-fire dispersal habitat
under this alternative [Alt. 3] would be highly likely to occur under no action as well due to
delayed fire-caused tree mortality death; and because that stand level effect would occur in the
larger context of a landscape not currently functional for spotted owl dispersal due to low
amounts of dispersal quality habitat; and because the removal of the [fire-damaged] green trees
in question is unlikely to retard the development of future NSO dispersal habitat, Alternative 3
would result in a determination of “no effect” with regard to spotted owls with regard to
Endangered Species Act Section 7 consultation with the USFWS.” Also, page 114 of the EA
states that “[n]one of the proposed actions will have any effect on the current spotted owl
population due to the lack of resident or territorial spotted owls within the project area. None of
the alternatives would have any effect on suitable nesting, roosting or foraging (NRF) habitat for
spotted owls because there is no suitable NRF habitat remaining in the project area post-fire.”
Road Actions
In order to maximize timber salvage on Matrix lands, I have decided to implement the
construction of approximately 0.30 mile of road as proposed in Alternative 3 in order to access
approximately 32 acres of salvage timber on Matrix lands. As described in the EA, “the road
construction is not likely to affect populations of any of the special status wildlife species
analyzed in this project” (pg. 61), nor is it expected that the road construction would contribute
sediment to nearby waterbodies if BMPs and PDFs are followed (pg. 91). My decision also
includes the full-decomissioning of three spur roads totaling approximately 0.81 mile, as
described on page 9 of the EA, because they are not needed for future management. This
decision results in a net decrease of approximately 0.5 mile of roads.
No salvage on DDRs, RR, ACEC – tree planting only
I have chosen not to salvage harvest in DDRs, RRs, and ACECs, but these special areas will be
planted with conifers, as proposed in Alternative 4. Leaving these areas unsalvaged will provide
short-term (5-10 yrs.) benefits to wildlife habitat values in the DDRs, RR, and ACEC (EA, pgs
62-65). The EA analysis showed that planting these areas (acreages listed below) will accelerate
“the development of the live tree component of late successional habitat to some degree, likely
decades faster than it would develop under the no action alternative” to maximize benefits for
wildlife in DDRs, ACECs, and RR, as described on pages 62-65 of the EA:
• 220 acres of DDR - 192 acres of conifer planting
• 419 acres of RR - 198 acres of conifer planting
• 807 acres of ACEC - 302 acres of conifer planting
Riparian Reserves
I have also chosen Alternative 4 for RRs because it will ensure that project implementation will
not adversely affect water quality or ACS objectives, and will meet RR BMPs for present and
future woody debris and snag retention. As stated in the EA on page 92, “Alternative 3 would
not meet ACS objectives due to water quality impacts. Alternatives 2 and 3 would not meet RR
BMPs for present and future woody debris and snag retention.”
Decision Record #2 – Oregon Gulch Environmental Assessment
Page 6 of 8
“High Quality Black-Backed Woodpecker Habitat”
The combination of Alternatives 3 and 4 that I have chosen will result in retention of
approximately 19% of “high quality (best) black-backed woodpecker habitat” as defined on
pages 52-53 of the EA, rather than the 40% recommended by the 2000 Altman conservation
strategy. To be clear, the 19% of “high quality” BBWP habitat is not the only forested land
within the project area that is being reserved from harvest. Approximately 2,430 acres, or 50%,
of the burned forest and woodland areas in the analysis area are being reserved from treatment
(see Table 2 above). These areas are expected to provide additional habitat that will be used by
BBWPs and other snag-dependent species.
In addition, the analysis of the BBWP concludes on page 61 of the EA that “[d]espite the
importance of high severity/high snag density burned forest to this species, salvage harvest in the
Oregon Gulch project area specifically, under any of the action alternatives, is unlikely to
depress the regional or overall population of BBWP to the point that they are at risk of
extirpation from the region or extinction. The Oregon Gulch fire is a very small percentage of the
0-5 year old burned forest habitat in the region, and within the entire range of occurrence of the
species, and BBWP occurs in low numbers in “green” habitats as well.”
Plan Conformance and Consistency with other Direction
The Klamath Falls Resource Area initiated planning and design for this project to conform with
and be consistent with the 1995 Klamath Falls Resource Area Resource Management Plan and
the 2001 Record of Decision and Standards and Guidelines for Amendments to the Survey and
Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines. The
actions selected from a combination of alternatives will help to move this portion of the
landscape towards the desired future condition considered in development of the RMPs. The
actions will comply with the Endangered Species Act, the Native American Religious Freedom
Act, cultural resource management laws and regulations, and Executive Order 12898
(Environmental Justice). This decision will not have any adverse effects to energy development,
production, supply and/or distribution (per Executive Order 13212).
Finding of No Significant Impact
No significant impacts were identified. No impacts beyond those anticipated in the KFRA
RMP/EIS will occur. Refer to the accompanying Finding of No Significant Impact.
CONSULTATION AND COORDINATION
Endangered Species Act (ESA) Consultation
No consultation with the U.S. Fish and Wildlife Service on the effects of the Oregon Gulch
Salvage and Rehabilitation Project was necessary. None of the proposed actions will have any
effect on the current northern spotted owl population due to the lack of resident or territorial
spotted owls within the project area. None of the alternatives would have any effect on suitable
nesting, roosting or foraging (NRF) habitat for spotted owls because there is no suitable NRF
habitat remaining in the project area post-fire.
The gray wolf is listed as endangered under the Endangered Species Act in this part of Oregon at
this time. There is no indication that the wolves are actually using the Oregon Gulch fire, or the
BLM stands within the Oregon Gulch fire. Absent a den in or near the project units, none of the
action alternatives are likely to affect gray wolves.
Decision Record #2 – Oregon Gulch Environmental Assessment
Page 7 of 8
There are no other threatened or endangered listed, proposed, candidate species or designated
critical habitat under the Endangered Species Act (as amended USDI Fish and Wildlife Service
(USFWS) 1973) that occur within the project area or that would be affected from project
activities.
Tribal Consultation
Consultation with the Klamath Tribes has been on-going since September 24, 2014 for the
Oregon Gulch Project Area and no concerns have arisen.
PUBLIC INVOLVEMENT
Initial Scoping
The scoping proposal was mailed to adjacent landowners, permittees, agencies, and other
interested parties on October 1, 2014. A public field trip to the Oregon Gulch project area was
held on October 22, 2014 in which three people participated. As a result of scoping, the BLM
received five letters from interested parties. All scoping comment letters and emails received can
be found in the Oregon Gulch EA project file. A summary of scoping comments and responses
can be found in Appendix D of the EA. The interdisciplinary team reviewed the scoping
responses and used the relevant comments in developing alternatives.
EA Comments
The EA and draft FONSI were made available for public review and comment from February 4
through March 5, 2015. The KFRA BLM received six letters of comment on the EA from
interested parties, agencies, and individuals. A summary of comments and BLM responses was
mailed to those who commented, and is also filed in the Decision File. The EA comments
received were all considered in making my Decision, but none of the comments presented cause
for the interdisciplinary team to revise the Environmental Assessment.
CONCLUSION
In consideration of public comments, the consistency with the RMP, and the finding that there
will not be any significant impacts, this decision allows for activities mentioned within this
document and included in the Oregon Gulch EA.
A Notice of Decision for these forest management actions (Decision Record#2) will be published
on April 14 in the Klamath Falls Herald and News. This notice will constitute the decision date
and as outlined in 43 CFR § 5003, Administrative Remedies at § 5003.3 (a) and (b), protests may
be made within 15 days of the publication date of the Notice of Decision. Protests shall be filed
with the authorized officer and contain a written statement of reasons for protesting the decision.
43 CFR 5003.3 subsection (b) states: “Protests shall be filed with the authorized officer and shall
contain a written statement of reasons for protesting the decision.” This precludes the acceptance
of electronic mail or facsimile protests. Only written and signed hard copies of protests that are
delivered to the Klamath Falls Resource Area office will be accepted.
/s/ Donald J. Holmstrom
Donald J. Holmstrom, Field Manager
Klamath Falls Resource Area
Lakeview District, Bureau of Land Management
Decision Record #2 – Oregon Gulch Environmental Assessment
4/14/2015
Date
Page 8 of 8
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Oregon Gulch Fire Salvage
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Environmental Assessment
Decision Record #2
17
Klamath Falls Field Office
Lakeview District
Bureau of Land Management
2795 Anderson Ave. #25
Klamath Falls, Oregon 97603-7891
(541) 883-6916
0
0.5
1:48,000
Miles
1
±
No warranty is made by the Bureau of Land Management as to the accuracy,
reliability, or completeness of these data for individual or aggregate use
with other data. Original data were compiled from various sources and may
be updated without notification. Acres displayed are approximate!
MXD: P:\lak\kfra\ID_TEAM_NEPA\Oreg on_Gu lch_Fire\Products\Salvage_EA_Maps\OregonGulch _EA_ Proposed_Alternativ e_15 0410.mxd
Prepared By : mlimb
Current Date: 04 /1 0/2015 03:43:49 PM